CSRD guide for the logistics sector

CSRD fundamentally changes sustainability reporting for logistics companies — from voluntary narrative to regulated financial disclosure with external assurance, board-level governance, and full integration with your annual report.

For logistics operations and finance teams, this means ESG data is no longer a sustainability project. It's operational reporting — requiring the same systems, controls, and traceability as financial data. Your TMS, ERP, and fleet management systems are your CSRD data foundation.

This guide covers what CSRD specifically requires from logistics companies, which ESRS topics carry the highest materiality, and how to build a system that connects to your operational infrastructure and passes assurance.

Implementation Timeline: UK vs EU

The original European timeline classified companies into waves: those already complying with NFRD (public companies with >500 employees) had to report in 2025 (FY2024 data), other large companies in 2026 (FY2025 data), listed SMEs in 2027 (FY2026 data), and non-European companies in 2029 (FY2028 data).

However, after the 2025 reforms ("stop-the-clock" and Omnibus), these dates were delayed by two years: large companies (non-NFRD) will report from FY2027 (report in 2028) and listed SMEs from FY2028 (report in 2029).

Summary Timeline for Spain/EU:

2025: First wave reports begin (NFRD companies with FY2024 data)

2027: Large companies not previously in NFRD start (FY2027 data, report in 2028)

2028: Listed SMEs begin (FY2028 data, report in 2029)

2029: Foreign companies with EU subsidiaries or significant sales start (FY2028 data, report in 2029)

The UK Position: Different Path, Same Direction

In the United Kingdom, CSRD as an EU directive does not apply. However, sustainability disclosure is gaining force through local regulations.

Since April 2022, large UK companies (all with >500 employees or £500M sales) must publicly disclose climate information according to TCFD (Task Force on Climate-related Financial Disclosures) taxonomy.

Additionally, the Government plans to adopt the IFRS Foundation standards (IFRS S1 general and IFRS S2 climate) as UK Sustainability Reporting Standards (UK SRS). These standards are expected to enter force from 2026 (for FY2025 reports).

Key Differences: EU (CSRD) vs UK

Base Regulation
Spain/EU (CSRD): CSRD Directive (EU) with mandatory ESRS standards.
United Kingdom: National laws such as the Companies Act and FCA rules, plus future "UK SRS" based on IFRS.

Mandatory Subjects
Spain/EU (CSRD): Large EU companies, listed companies including certain SMEs, EU parent subsidiaries, and non EU companies with more than €150M in EU sales.
United Kingdom: Large UK companies subject to TCFD since 2022 and, in the future, listed companies applying IFRS S1 and S2.

Materiality
Spain/EU (CSRD): Double materiality. Requires reporting both the company’s impact on society and the environment and the financial impact on the business.
United Kingdom: Financial or investor focused approach. Emphasis on sustainability risks and opportunities affecting the business, similar to ISSB.

Standards
Spain/EU (CSRD): Detailed and audited ESRS, European Sustainability Reporting Standards.
United Kingdom: IFRS S1 and S2 issued by ISSB, to be adopted as UK SRS under consultation, plus TCFD climate requirements.

Timelines
Spain/EU (CSRD): Phased implementation. Annual reports from 2025 covering FY24 for large companies, with a two year delay for others.
United Kingdom: Climate reporting obligation from FY22, ongoing. IFRS standards expected to become mandatory from 2026, tentative.

Audit
Spain/EU (CSRD): Mandatory external audit of the sustainability report.
United Kingdom: Not yet mandatory, pending SDR and UK SRS regulatory developments.

Penalties
Spain/EU (CSRD): National fines, potentially up to a percentage of revenue, for CSRD non compliance.
United Kingdom: Fines under the Companies Act, not ESG specific, with FCA supervision.

The main takeaway: whether you're in the EU or UK, rigorous ESG reporting is becoming mandatory. The frameworks differ, but the direction is the same: more transparency, more verification, more accountability.

How Logistics Teams Should Build CSRD Infrastructure

Step 1: Double Materiality for Logistics

Logistics double materiality assessments typically find as material: climate change (transport emissions, fuel dependency, transition risk from fleet electrification requirements), own workforce (driver conditions, warehouse safety, subcontractor labor standards), value chain workers (last-mile and subcontracted carrier conditions), and pollution (local air quality from urban operations).

The financial materiality lens should capture: fuel cost exposure to carbon pricing, regulatory risk from emission zone restrictions, fleet replacement CapEx for electrification, and insurance cost exposure from safety performance.

Step 2: Connect CSRD to TMS and Fleet Data

Logistics ESRS E1 data lives primarily in TMS route data, fuel card systems, telemetry, and subcontractor declarations. Design automated feeds from these systems into your ESG platform with emission factor libraries aligned to ISO 14083 or GLEC methodology.

Step 3: Subcontractor Data Architecture

The hardest CSRD challenge for logistics is subcontractor Scope 3 data. Design a tiered approach: primary data from strategic subcontractors via direct API or portal submission, secondary data with modelled estimates for long-tail carriers, clear documentation of estimation methodology and coverage rates.

CSRD Mistakes Logistics Companies Make

1. Using Inconsistent Emission Methodologies Across Modes

Logistics companies using different methodologies for road, rail, air, and sea transport create aggregation problems. Adopt a single methodology framework (ISO 14083, GLEC) and apply it consistently, documenting which version and factors are used per reporting period.

2. Not Addressing Subcontractor ESRS S2 Requirements

Logistics companies with significant subcontracted transport face ESRS S2 (value chain workers) requirements. This goes beyond emissions — it includes labor conditions, working hours, safety standards, and freedom of association for contracted workers.

3. Inconsistency Between CSRD Transition Plan and Fleet Investment Plan

If your ESRS E1 transition plan commits to fleet electrification by 2030 but your financial CapEx plan doesn't include those investments, auditors and investors will flag the contradiction. Finance and Operations must align on assumptions.

4. Not Treating Warehouse Energy as a Core KPI

Logistics companies often focus on transport emissions and underinvest in warehouse energy governance. Warehouse energy is typically Scope 1 and 2 with strong traceability from utility bills — and it's one of the easiest areas to demonstrate controlled improvement. Don't neglect it.

What to Look for in a Logistics CSRD Platform

TMS and Fleet Integration

The logistics CSRD platform must connect directly to TMS, fuel card systems, telematics, and fleet management software. These are the primary data sources for ESRS E1 disclosures — manual data entry from these systems is not sustainable.

Emission Methodology Library

Look for built-in support for ISO 14083, GLEC, DEFRA, and other logistics-specific emission methodologies. The platform should maintain factor libraries, document which version is applied per reporting period, and calculate tonne-km and delivery-level intensity metrics.

Subcontractor Data Management

The platform needs supplier portal functionality for subcontractor ESG data collection, tiered data quality management (primary vs estimated), and clear documentation of coverage rates and estimation methodologies for assurance.

Multi-Modal and Multi-Entity Support

Logistics groups with multiple entities, modes, and geographies need the same consolidation architecture as financial reporting: entity-level data, consistent methodologies, group rollup, and elimination of intercompany flows.

Why Dcycle is the Best Solution for Logistics CSRD

When choosing an ESG management platform for CSRD compliance, what really matters isn't just functionality – it's the ability to deliver a comprehensive, flexible solution oriented to the real value of ESG data.

We are not auditors or consultants. We are a solution designed for companies that want to measure, manage and communicate their ESG impact simply and efficiently.

Our objective is clear: enable every organisation to collect all their ESG information and distribute it automatically to different use cases, without complications or manual processes.

We centralise environmental, social and governance data from any source – TMS, WMS, fleet systems, carrier portals, ERP, spreadsheets – and convert it into standardised, traceable metrics ready for official reports. Companies can generate documentation compatible with EINF, CSRD, SBTI, ISO 14064, GLEC or any other standard in minutes.

Why Logistics Companies Choose Us

Designed for Operational Reality: We understand that in logistics, sustainability data is operational data scattered across multiple systems. Our platform integrates with the systems and processes you already use.

Multi-Modal by Design: Whether you operate road, rail, sea, air or intermodal, our calculation engine handles all modes with recognised methodologies (ISO 14083, GLEC, GHG Protocol).

Scope 3 Made Simple: Manage carrier data collection, validation and aggregation with workflows designed for logistics. Support data quality hierarchies and progressive improvement.

Complete Traceability: Every metric links back to source evidence – shipment records, fuel invoices, carrier reports, energy bills. This isn't just good practice, it's a requirement for external assurance.

Customer-Ready Reporting: Generate emissions reports by customer, route, mode or product with allocation transparency – exactly what your customers demand for their Scope 3.

Strategic, Not Just Compliance: We firmly believe sustainability should be a strategic lever for competitiveness, not an administrative burden. Our mission is clear: convert ESG data into smarter, more efficient and more profitable business decisions.

With Dcycle, logistics companies can control their information, reduce costs, automate processes, win more business and guarantee complete traceability of their ESG indicators.

In a market where measuring well is the difference between winning contracts and losing them, our proposition is simple: make sustainability work as a real engine for growth.

Frequently Asked Questions (FAQs)

What should I prioritise when implementing CSRD in logistics?

When implementing CSRD in logistics, prioritise three core elements: Scope 3 data collection, automation of operational data and traceability.

Scope 3 management is non-negotiable for logistics. Most of your footprint lives in subcontracted transport. Build a carrier engagement programme early, with clear data requirements and quality tiers.

Automation means collecting data directly from TMS, fleet systems, WMS and carrier portals without manual intervention. This reduces errors, saves time and ensures consistency.

Traceability means every number can be traced back to a source document (shipment record, fuel invoice, carrier report) with a clear calculation methodology. This is essential for audit and customer confidence.

Also ensure your solution handles multiple transport modes, supports recognised calculation standards (ISO 14083, GLEC) and can generate customer-specific emissions reports.

What are the main challenges for logistics operators under CSRD?

The main challenges are:

Scope 3 dominance: For most logistics operators, 70-90% of emissions come from subcontracted transport. Collecting reliable data from hundreds or thousands of carriers is complex.

Data fragmentation: Sustainability data lives across TMS, WMS, fleet management, carrier portals, fuel card systems and energy bills. Consolidating it requires careful integration.

Allocation complexity: Shared loads, multimodal shipments and consolidation centres create allocation challenges. You need clear, defendable rules.

Customer pressure: Even if you're not obligated, your customers will demand detailed emissions data for their Scope 3 reporting.

Modal diversity: Different calculation methodologies for road, rail, sea and air transport. You need a platform that handles all modes consistently.

Audit readiness: Unlike previous sustainability reports, CSRD requires external assurance. Your data and processes must meet audit standards.

How does CSRD differ between EU and UK logistics operators?

EU logistics operators must comply with CSRD and ESRS, which require double materiality, detailed disclosures across environmental, social and governance topics, and external audit.

UK logistics operators follow TCFD for climate (already mandatory for large companies since 2022) and will likely adopt IFRS S1/S2 standards focused on financial materiality and investor decision-usefulness.

The practical difference: CSRD is more comprehensive (covering broader ESG topics) and more prescriptive (specific datapoints and methodologies), while UK standards focus more narrowly on climate and financial impact.

However, the direction is the same: more rigorous ESG disclosure, more verification, more accountability. UK logistics operators with EU customers, EU operations or EU-listed securities will likely need to comply with both frameworks.

Can small logistics operators benefit from CSRD compliance even if not required?

Absolutely. Even if you're below the mandatory thresholds, building a CSRD-aligned ESG system delivers concrete benefits:

Customer requirements: Large shippers increasingly require detailed emissions data from logistics providers. Having robust data positions you as a preferred partner and helps you win tenders.

Access to finance: Banks and investors offer better terms to companies with transparent ESG performance and credible improvement plans.

Operational efficiency: Measuring fuel consumption, route efficiency, load factors and energy use properly almost always reveals cost-saving opportunities.

Risk management: Understanding your environmental and social risks helps you prepare for regulatory changes (ETS Maritime, carbon pricing), fuel price volatility and market shifts.

Competitive differentiation: In a market where sustainability matters, verified ESG data is a sales tool.

The investment in ESG data infrastructure pays dividends whether or not compliance is mandatory.

How long does it take to implement a CSRD-ready system in logistics?

For a typical logistics operator, a realistic timeline is:

90 days for minimum viable system: Scope definition, materiality assessment, top carriers engaged, main data sources connected (TMS, fleet, energy), basic controls in place and first draft disclosures with identified gaps.

6-12 months for full implementation: All material datapoints automated, Scope 3 coverage targets met, complete controls, evidence management, workflow approvals, audit-ready documentation and first complete CSRD report.

Ongoing improvement: ESG reporting is not a one-time project. Expect continuous refinement of data quality, expansion of carrier coverage, deeper customer integration and more sophisticated analytics.

The key is to start with a solid foundation – clear scope, cross-functional governance, robust data model, carrier engagement strategy and the right technology platform. Building on shaky foundations wastes time and creates problems later.

With the right approach and the right tools, CSRD compliance becomes a manageable process that strengthens your business rather than burdening it. In logistics, the companies that master ESG data will win the contracts of tomorrow.